In the modern data-driven economy, protecting personal information is not only a matter of regulation—it is a business imperative. India’s recent enactment of the Digital Personal Data Protection (DPDP) Act 2023 is a major breakthrough in the nation’s privacy and data protection journey. In contrast, the General Data Protection Regulation (GDPR), enforced in the European Union since 2018, is still the gold standard worldwide.
As businesses move towards DPDP compliance for companies, it’s important to comprehend how India’s approach stacks up against international standards such as GDPR. Whether you’re an Indian enterprise expanding internationally or a foreign company managing Indian user information, getting both laws right will be the key to your compliance success in 2025 and beyond.
Overview of the DPDP Act 2023
The DPDP Act 2023 is India’s all-encompassing law aimed at governing the processing of personal data. Enacted to balance innovation with user rights, it establishes a legal regime for data fiduciaries—who are organizations gathering and processing personal data.
Applicability – The legislation will cover any organization functioning in India or handling the personal data of Indian nationals, irrespective of location abroad. This requires domestic companies as well as international businesses with an Indian clientele base to take the implications very seriously.
As a DPDP compliance solution provider, DataFram helps businesses review and fulfil these legal requirements with transparency and effectiveness. Our digital personal data protection act consultants help your data processing comply with the changing expectations under the Indian law.
Overview of GDPR (General Data Protection Regulation)
The General Data Protection Regulation (GDPR) entered the EU in 2018 and created an international standard for the protection of personal data. It provides rights to citizens, and places strong obligations on companies gathering/handling their data.
Application – The GDPR applies throughout the EU but also affects companies beyond the region that are providing goods or services to EU residents or tracking their online behaviour.
Note —
While your company may not provide GDPR services, understanding it helps benchmark best practices. This is especially if you’re aiming to implement a globally-aligned privacy framework.
DPDP Act vs. GDPR – Key Differences Explained
Factor | DPDP Act 2023 | GDPR |
Consent | Based on notice and purpose | Explicit, opt-in |
Data Principal Rights | Limited: right to info, correction | Broad: access, erasure, portability |
Penalties | Up to ₹250 crore | Up to ₹180 crore INR (as of July 2025 exchange rates) or 4% of global turnover |
DPO Requirement | Conditional (for significant data fiduciaries) | Mandatory for many organizations |
Cross-border Transfers | Permitted with whitelisted countries | Allowed with adequate safeguards |
Grievance Redressal | Data Protection Board of India (DPBI) | Supervisory Authorities in each EU member state |
Jurisdiction | India | EU + Global applicability |
These differences between the DPDP Act vs. GDPR are critical in evaluating exposure under either law. Our data protection consultancy company assists clients in conducting gap analysis between both frameworks to facilitate complete readiness.
Key Similarities Between DPDP and GDPR
Though structural differences exist, the DPDP Act and GDPR have common data protection tenets –
- Accountability – Organizations need to establish responsibility in the processing of data.
- Purpose Limitation – The data can only be gathered for distinct, clear, and legal purposes.
- Security Safeguards – It is obligatory to have reasonable data protection measures in place.
- Legal Processing – All processing of personal data has to be lawfully justified.
- Notice and Consent – Both laws call for openness about the usage of data and require user consent.
The above similarities present a good starting point for businesses that want to adhere to both regulations at once.
Also Read: Best Data Migration Tools in 2025
Which Law Applies to You?
Indian businesses with EU clients – If you’re processing EU citizens’ data, GDPR is applicable—even if you’re based in India.
Offshore companies catering to Indian clients – The DPDP Act 2023 applies here, necessitating local compliance measures.
Our data protection consulting servies assist in determining your business’s exposure under both frameworks and guides implementation. Whether you require policy updates or develop consent workflows, our team makes your compliance airtight.
DPDP Act Compliance in 2025
Preparing for DPDP compliance by having data practices ready for 2025 begins with professional support and strategic planning. The important steps include –
- Assessment and Audit – Perform internal audits to plot current data practices. Our DPDP audit and assessment pinpoints gaps and recommends enhancements.
- Data Mapping – Follow data wherever personal data is located, and trace who else accesses it and why.
- Consent Management – Set up processes for clear, purpose-based consent collection.
- Policy Documentation – Revise privacy policies, grievance redressal mechanisms, and third-party contracts.
An experienced DPDP compliance solution provider, like our team at DataFram, can ease the process by providing end-to-end assistance—from assessment to implementation.
Conclusion
Though both DPDP Act 2023 and GDPR intend to safeguard individuals’ rights over their data, they share considerable differences in scope, enforcement, and expectations of compliance. For businesses active in cross-border settings, these differences are more than a regulatory requirement—they’re a strategic imperative.
Cutting through the complexity alone can be daunting when it comes to compliance. That’s why it’s a good idea to get professional advice.
Unsure where to start? Start with our expert DPDP Act compliance services or schedule a call with our Hire DPDP consultant team for bespoke compliance support.
With DataFram’s specialised skill and integrated consulting methodology, your company can confidently comply with global and local data privacy legislation—all, minus the uncertainty.